Providers want the Centers for Medicare and Medicaid Services to reconsider cutting physician pay and avoid financial repercussions that could force them to scale back care.
Comments healthcare industry groups wrote in response to the Medicare physician fee schedule proposed rule for 2024, which CMS issued in July, object to the agency's plan to reduce doctor pay 1.25% next year.
The draft regulation, expected to be finalized this fall, proposes policies beyond new reimbursement rates and includes provisions designed to advance health equity and expand access to care. Organizations representing physicians, hospitals, medical schools, long-term care providers, health insurance companies and others submitted comments on the rule to CMS.
Hospital and physician groups expressed concern about the proposed changes to reimbursement, which they argue don't account for rising costs, inflation, supply chain problems and workforce shortages.
“There is a discrepancy between the cost of running a physician practice and actual payment for physician services. These reductions in payment would have a devastating impact on physicians and other healthcare professionals and jeopardize patients’ access to care,” the Association of American Medical Colleges wrote.
The American Hospital Association echoed those sentiments and cited a Medicare trustees report that shows Medicare physician reimbursement declined more than 20% from 2001 to 2021 when accounting for inflation. “This negative update would pose significant risks to patients’ access to care and health systems’ financial stability, particularly for providers serving historically marginalized communities,” the AHA wrote.
Some safety-net hospitals maintained that physician fee reductions could hamper their ability to provide services. New York City Health + Hospitals, for example, wrote that it “cannot sustain further reimbursement cuts.”
While CMS is proposing to scale back payments overall, it is considering raising rates for primary care and other direct patient care services. The agency would reduce reimbursements for other specialities to finance that pay hike, which the California Hospital Association contended would pit providers against each other for scarce resources.
“Shifting payment cuts from one type of provider ‘whack-a-mole’ style will only exacerbate access issues in another portion of the healthcare delivery system for Medicare beneficiaries and underserved individuals,” the California Hospital Association wrote.
Commenters offered support for CMS' proposal to extend Medicare coverage of telehealth and virtual care services, first made possible during the COVID-19 pandemic, through the end of next year and advocated making this policy permanent.
“The COVID-19 [public health emergency] has made clear that telehealth is a key feature in providers’ toolboxes and, thus, has a permanent place in the future of care delivery,” the AHA wrote.
Nursing home trade group LeadingAge wrote that the Medicare coverage of telehealth supports its members at a time when they are struggling to hire.
The AHA and the Federation of American Hospitals endorsed a CMS plan to pay the same for home-based virtual care as in-person visits, while the health insurance trade association AHIP opposes it.
“A proposal that requires telehealth services be paid the same as in-person care will suppress innovation, encourage the maintenance of brick-and-mortar facilities and stifle the cost savings potential of telehealth,” AHIP wrote.
Changes to boost ACO participation
Providers that commented on the draft regulation were generally supportive of CMS' proposals for Medicare Shared Savings Program accountable care organizations.
CMS aims to revise quality reporting and financial benchmarking requirements and its assignment methodology to increase access to accountable care for patients seeking primary care from nurse practitioners, physician assistants and clinical nurse specialists. The agency estimates the proposed rule would increase Medicare Shared Savings Program participation by as much as 20% next year.
Although most comments on the Medicare Shared Savings Program provisions were positive, AHIP articulated concerns that the agency may inappropriately assign beneficiaries to ACOs. “We recommend that CMS conduct further analysis to ensure that the proposed assignment changes do not have unintended consequences,” AHIP wrote.
The National Association of ACOs was mostly pleased with proposed changes to the Medicare Shared Savings Program. “We are especially gratified by your proposals to cap the regional risk score, use the same risk model in the benchmark and performance years, and offer a new quality reporting option for ACOs. Many of these policies are responsive to concerns and suggestions raised by our members,” NAACOS wrote.
Still, NAACOS wants CMS to reconsider plans that it argues could increase clinician burden, including electronic quality reporting and beneficiary notifications, and to support inclusion of all providers in the model.
LeadingAge also recommended that CMS broaden provider participation beyond physicians and hospitals. “We encourage CMS to explore a residential-based ACO model where the nursing home is at risk for total cost of care and coordination with physicians, hospitals, health systems and other providers,” the group wrote.